The Hidden Cost of Expired BAAs in Healthcare
When it comes to HIPAA compliance, one document is often treated as a formality. That document is the Business Associate Agreement (BAA).
Many healthcare leaders assume BAA compliance is covered once the signature is in place. But expired agreements and incomplete coverage can quietly create massive risk inside your operation.
If you're not actively managing HIPAA Business Associate Agreement compliance, you're leaving your facility exposed.
What Is a Business Associate Agreement and Why It Matters
A BAA is a required legal contract under HIPAA. It defines how a third-party vendor will protect Protected Health Information (PHI) on your behalf.
Any vendor that handles PHI must be covered by a valid BAA. This includes:
- Diagnostic laboratories
- IT service providers
- Billing contractors
- Therapy staffing firms
- Waste disposal vendors handling patient materials
If they can access, transmit, or store PHI, the law requires a current and enforceable BAA.
What Can Go Wrong
We have seen facilities operate for months, sometimes years, with one or more expired or missing BAAs. Here’s what that risk looks like:
One facility assumed its lab vendor had a valid BAA. When a minor PHI breach occurred, they discovered the agreement had expired 14 months earlier. The vendor was off the hook. The facility paid the regulatory fine and had to notify more than 300 residents’ families.
Top BAA Compliance Failures
- Expired agreements that were never tracked
- Subcontractors operating without coverage
- BAAs that do not match the current scope of services
- New vendors added without documentation
- “Standard” templates that ignore real risk
If these gaps exist and your vendor causes a breach, you’re still responsible. Your BAA is your legal defense. If it is out of date, it is worthless.
What You Can Do Today
- Review every vendor with access to PHI
- Confirm that each BAA is current and accurately reflects the work being done
- Ask vendors whether they use subcontractors and request documentation
- Set a calendar reminder to review all BAAs annually
- Build BAA review into your vendor monitoring workflow, not just onboarding
How MonitorPoint Helps
MonitorPoint tracks more than task completion and KPIs. We verify that every vendor is covered by a valid BAA, flag outdated agreements, and escalate when documentation is missing.
This is part of how we help healthcare facilities stay audit-ready and protected against exposure.
Expired BAAs Are Not Just Oversights. They Are Breach Risks.
If you are not actively managing HIPAA Business Associate Agreement compliance, you are gambling with your license.
MonitorPoint helps eliminate that risk. If you don’t know your BAA status today, that is the best place to start.
